ALATION GLOBAL PRIVACY NOTICE FOR EMPLOYEES, CONTRACTORS AND CANDIDATES
Last Updated - May 5, 2023
Alation, Inc. and its affiliates (“we”, “us”, “our” or “Alation”) are committed to ensuring that the personal data of our employees, former employees, contractors (together, “Team Members”) and of job applicants (“Candidates”) is handled in accordance with applicable laws. This privacy notice (“Notice”), together with the Employee Handbook (available for employees only), explain what personal data Alation collects about you, how we use this personal data and your rights to this personal data. Alation will act as a controller of this information, unless this Notice specifically states otherwise.
This Notice applies to the handling of your personal data as a Team Member or Candidate. If you are looking for information about how we collect personal data from visitors of our website or users of our products and services, please review the Alation Privacy Notice.
In this Notice, the following terms apply:
“Personal data” means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
“Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction
“Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
1. WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU AND WHY
The personal data we process about you may vary according to whether you are a Team Member or a Candidate, the jurisdiction where you are located and local legal requirements. Most of the information we get about you we receive directly from you, but also from employment agencies, from referees (external or internal), from security clearance providers, from providers of staff benefits, amongst others. Below you will find a summary of the main types of personal data we process.
Identification and Contact Data
Name, photograph, mailing address, telephone, email address, emergency contact details, employee ID, badges, government identifiers
Information related to Candidate qualifications, past employment, interview notes, references, immigration status and documentation, residency permits and visas, national ID/passport, and other official documentation in support of authentication or eligibility for employment, salary expectations, signature
Credit history and criminal records data utilized for background screening and vetting purposes where permissible and in accordance with applicable laws
Your job title/position, office location, employment contract number, offer letter, hire and termination date, exit interview, performance evaluations or reviews, disciplinary actions, training and development plans
Your spouse and dependents’ first and last names, dates of birth and contact details, health information, leaves of absence, vacation allowance, insurance information
Your bank account details, tax information, salary, expenses, company allowances, bonus information, stock and equity grants and other information necessary to administer payroll, taxes and benefits
Systems and Workplace Data
Information required to access Alation’s computing resources and facilities, such as IP addresses and login information, internal communications, video and call recordings, calendar entries, data required to access Alation’s premises such as CCTV and security controls
Date of birth, gender, race/ethnicity, veteran status, information about disabilities, sexual orientation, gender identity
Other information you choose to share with us, such as answers to feedback surveys, social preferences, hobbies
2. WHY WE PROCESS YOUR PERSONAL DATA
We process your personal data as set out above for:
a) To administer your employment contract, offer letter and other commitments we have made to you and manage our human resources processes
During the hiring process, we process Candidates’ personal data to determine suitability and eligibility for a role. We process Team Members’ data primarily for the purposes of managing their employment or working relationship and to fulfill our obligations under the contract, including onboarding, payroll, benefits administration, tax reporting, performance reviews, and termination of employment.
b) Other legitimate business purposes
We may process your personal data when necessary for our legitimate interests, e.g., for general HR administration, general business management and operations, such as strategic business planning and business travel, disclosures for auditing and reporting purposes, conducting surveys, internal investigations, physical and cybersecurity, provision of employee services and facilities and diversion and inclusion initiatives. We may also use your personal data, including Systems and Workplace Data, for organizational and individual analytics and insights to improve Alation’s operations and for purposes of reviewing, rewarding and coaching employees on their performance and for the administration and assessment of training.
c) Legally required purposes
We may process your personal data to comply with laws and regulations, for example, labor and employment laws, health and safety, tax, anti-discrimination laws, global migration, or to exercise or defend Alation’s legal rights.
3. WITH WHOM DO WE SHARE YOUR PERSONAL DATA
We do not sell your personal data and we only share your personal data with those who have a legitimate business need for it. Whenever we permit a third party to access your personal data, we will ensure the personal data is used in a manner consistent with this Notice and any applicable internal policy, and we will obtain your consent to any disclosure of personal data where required by applicable law. You can see the type of third parties we may share your personal data with and the reasons for doing so in the table below.
Reason for sharing
Team Members and Alation’s affiliated companies
In order to administer your employment as seen above.
To enable third parties to provide services such as insurance providers, pension administrators and other benefits providers, childcare providers, payroll support services, relocation, tax and travel management services, facility management, security services, health and safety experts.
Consultants and Advisors
To seek legal advice from external lawyers and other professionals such as accountants, management consultants, or in connection with corporate transactions.
In case we believe we are compelled by applicable law or where necessary to exercise, establish or defend legal rights, including to enforce our agreements and internal policies.
Other Third Parties
To protect Alation’s rights or property; protect your vital interests (such as safety and security); otherwise in accordance with your consent.
3.1 How do we handle international transfers of personal data
As a global organization, we may transfer your personal data to countries outside of the country/region where you work, for example, when we or one of the third parties we engage operates in different countries. We will only transfer your personal data to another country in accordance with applicable laws and we will ensure that there is adequate protection in place for your data.
4. WORKPLACE SECURITY AND MONITORING
Alation monitors its IT and communications systems through automated tools such as network authentication, anti-malware software, website and spam filtering software, access and transaction logging and mobile device management solution, primarily for our legitimate interest to protect our business, employees, customers and business partners and for network and device management and support, recordkeeping and other legitimate purposes as permitted under applicable law.
We also monitor our offices and workplace facilities through video monitoring (CCTV) and badge scans. CCTV is not used in private spaces nor is it used to monitor employee workstations for performance reasons.
All information transmitted, stored or recorded on our IT and communications systems are presumed to be business-related and may be monitored or accessed by us in accordance with applicable law and workplace regulations. Alation will conduct our monitoring in a way that is proportionate and as minimally invasive as possible.
5. RETENTION AND SECURITY OF YOUR PERSONAL DATA
We will keep your personal data for as long as we need to fulfill the purposes as described above, in accordance with applicable law or regulatory requirements and as documented in our corporate data retention policies.
We maintain physical, electronic and procedural safeguards to protect the confidentiality of your personal data, for example, we store the personal data you provide on limited access computer servers that are located in controlled facilities and we restrict access to the personal data to people with a ‘need-to-know’.
6. WHAT ARE YOUR RIGHTS TO YOUR PERSONAL DATA
You have the right to make choices about your personal data as a Candidate or as a Team Member. These rights include, where applicable and in accordance with applicable law, the right to update your personal data, the right to have your data deleted and the right to request information about how we are processing your personal data.
If you are a Candidate and you want to exercise any of these rights: please contact the recruitment team you worked with or email Alation’s Privacy Team: email@example.com
7. QUESTIONS AND QUERIES?
Feel free to contact us via email: firstname.lastname@example.org
Changes to this Notice
We may occasionally update this Notice. You can see when this Notice was last updated at the top of this Notice. If there are material changes to this Notice or in how Alation processes your personal data, we will use reasonable efforts to notify you about it, in compliance with applicable law.
8. INFORMATION FOR CALIFORNIA BASED TEAM MEMBERS AND CANDIDATES
The California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020, effective as of January 1, 2023 (“CCPA”), requires businesses that collect personal data of California residents to make certain disclosures regarding how they collect, use, retain and disclose such information. This section 8 of the Notice facilitates those requirements.
The personal data we collect is described in Section 1. The purposes for which we collect the personal data are described in Section 2. The sources from which we collect that data are described in Section 1. We retain personal data as described in Section 5.
Alation does not sell personal data collected as part of our application and recruitment process nor employment. Alation does not use or disclose sensitive personal data for purposes other than those permitted purposes under the CCPA.
California law gives California residents the right to make certain requests with regard to their personal data, as set out in Section 6 of this Notice.